On July 14, 2025, CMS released the proposed Physician Fee Schedule (PFS) rule for CY2026.
Find the press release here:
The press release lists several subcategory Fact Sheets, find the main one here:
The full rule was published in Fed Reg on July 16 here:
An article on remote monitoring policy issues here.
Laboratory
I don't see much of direct special relevance to laboratories.
Quality Measures
CMS is booting ten quality measures, many of them for being "severely topped out." Not too surprisingly, a measure that encourages COVID vaccination is also being dropped. There is also some rulemaking about topped-out measures (512.725(h)(3) and see also 414.1305.
Other measures are dropped because they are no longer aligned to clinical guidelines or the measure steward is bowing out.
In section IV.A.4.d.1.b, propose to revise the definition of a high-priority measure to remove "health equity" criterion; to revise 414.1305. Discussion at p. 32715 noting "we believe that our [prior] definition of health equity was confusing."
There are ongoing changes in MIPS and other quality systems, which can affect conversion factors rates (how RVUs are converting to payment dollars.) Category "Achieving Health Equity" to be removed from MIPS.
Direct Supervision - Virtual Now
CMS rewrites a section of 42 CFR 410.32, which gives supervision requirements for diagnostic tests (mostly meaning imaging tests like MRI paid in RVUs). Direct Supervision may include "virtual presence of the physician" by audiovisual technology.
Comment on Pricing and Policy for Software
Page 32503ff. especially 32506-7. Comment on pricing for software or AI is also in the OPPS rule.
Updates:
Use of OPPS Data for PFS RVU Price-Setting
CMS writes, "For several kinds of PFS services, we are proposing to deviate from the use of the AMA survey data, and instead utilize data from auditable, routinely updated hospital data to set relative or absolute rates..." (inspection copy, 66). CMS got this authority in PAMA 2013. It's a policy change that might have big impacts on RVUs in some cases.
Urgent Care Centers
CMS is concerned that some urgent care centers are more like emergency rooms while others are more like "a typical general practitioner's office." Inspection copy, 66ff.
"...Commenters stated that the current place of service (POS) definitions are inadequately differentiated, especially if CMS wishes to encourage proliferation of the type of urgent care centers that can provide alternatives to EDs" [for lower-intensity services now seen too much in EDs esp after-hours].
